- 2 -
Penalty
Year Deficiency Sec. 6662
1990 $11,276 $2,255
1991 22,232 4,446
1992 36,483 7,297
By way of an amendment to respondent's answer, respondent
sought increased deficiencies and penalties against petitioners
under section 6214 for each of the years in issue, alleging that
petitioner David Smith received taxable distributions from a
pension plan under section 72(p) and (t). Respondent asserted
that petitioners are liable for increased income tax deficiencies
and section 6662 penalties of:
Penalty
Year Deficiency Sec. 6662
1990 $3,185 $637
1991 13,939 2,788
1992 21,413 4,283
The increases result in combined income tax deficiencies and
penalties in controversy as follows:
Penalty
Year Deficiency Sec. 6662
1990 $14,461 $2,892
1991 36,171 7,234
1992 57,896 11,580
On brief, petitioners conceded that petitioner Mr. Smith received
distributions from his pension plan taxable under section 72(p)
and (t).2 The following issues remain for our consideration: (1)
2However, petitioners have not conceded that they are liable
for the increased sec. 6662(a) accuracy-related penalties
asserted in respondent's Amendment to Answer.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011